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Home My WebLink About06-1998 TINA Y. LAWYER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0& -}'19 9 Civil Term CHARLES A. LAWYER, JR., Defendant ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. (!)~.199f Civil Term TINA Y. LAWYER, vs. CHARLES A. LAWYER, JR., Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Tina A. Lawyer, a competent adult individual, who has resided at RR# I Mapleton Depot, Pennsylvania, 17052 since August 2005. 2. Defendant is Charles A. Lawyer, Jr., a competent adult individual, who currently resides at 85 Conrad Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on February 28, 2003 in Frederick, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. . . 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I veritY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. ~~ f' . U//\~ /Tina A. , ~ntiff Respectfully submitted, -~ D", Y Is-(G \. A'./ " Jan Adams, Esquire I . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -'-'~" f:: g ~; (~ V\ ~ -0 ~ C".. <:'- :rr~ - '" ~ ':::t- '-..J t"-- ,_ ~ \f) ~- ::, ~'~ 11: ~.-d -#: :':1.: c-- '__ .: ___ --C - --roc; (j l! '-' c7c...d 'J~ ~~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PEl'-INSYL VANIA TINA Y. LAWYER, vs. No. 06 - 1998 Civil Term CHARLES A. LAWYER, JR., Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this April 24, 2006, I, Jane Adams, Esquire, hereby certify that on April 18, 2006, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Charles A. Lawyer, Jr. 85 Conrad Rd. Carlisle, Pa. 17013 DEFENDANT . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: x 8. Received by ( Printed Name) D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: ,.f1 No CHARLES A. LAWYER 85 CONRAD RD CARLISLE PA 17013 JR 3. Service Type p"'Certified Mail 0 Express Mall o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) J2f'Ves 2. Article Number (rransferfromservlce" 7004 1350 001]3 7288 4493 PS Form 3811, February 2004 Domestic Return Receipt 102595-o2-M-1540 ~ Jan Adams, Esquire 1. . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ._1 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TINA Y. LAWYER, vs. No. 06 - 1998 Civil Tenn CHARLES A. LAWYER, JR., Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A c.:Jmplaint in divorce under section 3301(c) of the Divorce Code was filed on April 7, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verity that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: S 1/!:>-/6ro ~d~d1 Tina Y. " la' tiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DNORCE DECREE UNDER S330Hc) AND S330Hd) OF THE DIVORCE CODE I. I consent to entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property. lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verity that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ctll~{6h -~T' y-~htf ma. e, a tl ~ ~ ~ ~ ~~ -oq.? t; f1'1f"!: G? z.~r - :o~ "'::"? I ,:;) V'1) ..... '=2.,., ~": ---n ~~ -0 c~B ~" ::It " (<'\ ~?;o a - "" :PC:: .' ~ ~ c.n - Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TINA Y. LAWYER, VS. No. 06 - 1998 Civil Term CHARLES A. LAWYER, JR., Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on April 7, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fInal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifIcation to authorities. Date: 8 - It/ - 0 (. ~ WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER S330Hc) AND S330Hd) OF THE DIVORCE CODE I. I consent to entry of a final decree of divorce without notice. 2. I understand that I may,lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.. ~4904 relating to unsworn falsifIcation to authorities. Date: 8-14-0<.0 ~. <2 ~ -0 th~ f\"\f\ ~. """"'-;1, '2- C~ (1) ?~- :':::.' ~t' %8 ~PC: 'Z, :2 q, ~~ :i\q -.....l 0.0 ~"1"' --0 1',,2 B ::s: lSi'T' _ A ;.;, ~ - ~ ~ ~ G'> Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ; No. OLY - I 4 q ~ Civil Term TINA Y. LAWYER, vs. . CHARLES A. LAWYER, JR., Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under &330l(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: April 18, 2006. 3. Date of execution of the affidavit of consent required by 3301 ( c) of the Divorce Code: By Plaintiff: August 15,2006. By Def.endant: August 14, 2006 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 17,2006. ',', Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 17, 2006 Date: l5/ ~)D/O~' L ? ClWv~ Adams, Esquire I . No. 79465 64 S. Pitt Street Carlisle, Pa. 170 \3 (717) 245-8508 Attorney for Plaintiff n C.~ n '-' -n -' ~ C~) c' " c..:, .< 1'-' '+''+'+.'+'10:'+ . ~~~ ~~~~~~~~ ~+. *~~ ~~~+'++''+'Io:'+'+'+ '+'+ . . ... . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . . . . . PENNA. STATE OF Tina Y. Lawyer, Plaintiff . . . . . . . . . . . + . . . . No. No. 06 - 1998 Civil Term VERSUS Charles A. Lawyer, Jr, Defendant . + + . . . . . . . . + + . + + + + + + + + . + . . . + + . + + + . + + + + + + + + . + + + + . . . . + . . + + . + + . + + . + + + . . DECREE IN DIVORCE AND NOW, S e..0~"" \t. ~ l.()clo , IT IS ORDERED AND Tina Y. Lawyer DECREED THAT Charles A. Lawyer, Jr. AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , OEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . None. By THE COURT: ~'-\. "- ATTEST: G~~ PROTHONOTARY * ~ +.,t':I' Of + + . + + + + + + . . + + + + + + + + + + + + . + . + + . + . + . . . . . . . . . . . . . . . . . . . . . . + . . . + . . . . . . . . . . . . . . . . + + + . . . J. . . . . . . . + . . . . . . H ""'t''f.'+'I' . . Of. Of. +; '+ 't 't;t:i'::t: or. '+' Of. +. 'to 'to 'to + . ++ 'to'f.+. 'f''f.'f.+'f.'f. ++;\' ++';f 'I'+'f.'f. 'f' :f +'f. ;#' ff ~ ?'I'> 1~ 1/-. -IV it" f'- ~ 1/,/", p:; 'l1 II b . '. " ---